Presented to:
By:
Date:
Federal AviationAdministrationCurrent Activities
Affecting FAA ADs
EASA AD Workshop
FAA Transport Airplane Branch
November 20, 2018
Federal AviationAdministration
Impacts to FAA ADs
• FAA Reauthorization Act of 2018, Section
242
• Incorporation by Reference (IBR) the foreign
AD/Mandatory Continuing Airworthiness
Information (MCAI) AD
• Rescission of older FAA ADs (ADs
terminated by a newer AD)
• Required for Compliance (RC) ADs
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Federal AviationAdministration
FAA Reauthorization
• FAA Reauthorization Act provides
limitations for which foreign ADs (and
AMOCs) may be accepted.
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Federal AviationAdministration
U.S. AD ProcessThe FAA must comply with the Administrative
Procedure Act (APA):
– Requires notice and opportunity for comment; the
AD preamble is “the heart of compliance with the
Administrative Procedure Act.”
– Allows for no notice only if “good cause” exists.
– Requires reasonable responses to public comments.
– Must meet not only APA requirements, but also the
Office of the Federal Register (OFR) and FAA
policies and requirements.
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Federal AviationAdministration
U.S. AD Process, cont’d
Freedom of Information Act (FOIA)
5 U.S.C. 552(a) (FOIA) “Except to the extent that a
person has actual and timely notice of the terms thereof, a
person may not in any manner be required to resort to, or
be adversely affected by, a matter required to be
published in the Federal Register and not so published.
For the purpose of this paragraph, matter reasonably
available to the class of persons affected thereby is
deemed published in the Federal Register when
incorporated by reference therein with the approval of the
Director of the Federal Register.”
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Federal AviationAdministration
U.S. AD Process, cont’d
Takeaway:
Currently, FAA legal and leadership teams are
evaluating the impact of the Reauthorization
Act and how implementation may affect these
ADs and AMOCs.
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Federal AviationAdministration
IBR the MCAI AD
• First introduced in NPRM 2018-NM-043-AD
• Currently being used on a trial basis for
certain EASA ADs that affect Airbus
airplanes.
• Limitations:
1) Few (if any) differences exist between MCAI and
FAA ADs (US legal enforceability requirements).
2) FAA needs to have manufacturer’s approval to post
the required service information referenced in the
MCAI in the FAA Docket after the AD is published.
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Federal AviationAdministration
IBR the MCAI AD, cont’d.
Intent:
1) Expand process to other foreign ADs,
provided trial is successful and we receive
appropriate permission from foreign
manufacturers to post service information.
2) Utilize foreign AD requirements as much
as possible (w/ minor differences – if any)
3) Simplify and expedite FAA ADs
4) Set foundation for Reauthorization Act
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Federal AviationAdministration
Supersedure/Stand-Alone AD
Intent:
1) Simplify new FAA AD (w/o restating previous
AD requirements).
2) Terminate requirements of older ADs after
accomplishment of new AD actions.
Primary Downside:
Adds another AD that affected operators
need to track.
Question commonly asked:
Will the FAA ever remove the terminated AD?
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Federal AviationAdministration
Supersedure/Stand-Alone AD, cont’d
Answer:
Yes.
Requirements to Remove Terminated AD:
1)Compliance time has ended for new AD
2)Any terminating actions from older AD are
addressed with new/other ADs (don’t want to
lose the terminating action relief in the
removed AD)
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Federal AviationAdministration
FAA ADs – U.S. Airplanes
Evolution of ADs affecting U.S. airplanes:
• Extract required actions from published SBs
• Require actions identified as RC in SB
• Require actions identified as RC in
Requirements Bulletin (RB) (i.e. 2 part SB)
Intent:
• Simplify FAA ADs by pointing to SB that only
requires those actions necessary to address
the unsafe condition.
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Federal AviationAdministration
Background
• In 2000, the agency met with major U.S. air
carriers to get feedback on FAA transport
ADs:
– Are our ADs easy to read, and easy to understand?
– How could we simplify our ADs?
– What other suggestions did the operators have for
ADs?
• The air carriers’ response was: “Just tell us
to do the service bulletin (SB).”
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Federal AviationAdministration
“AD-Friendly” Service Bulletins
• In 2000, we began meeting with Boeing as
the first “AD-Friendly (ADF) SB” team.
• FAA goal was to streamline the transport
AD process by:
– Identifying and implementing improvements to the
format and usability of SBs.
– Ensuring legally enforceable, “AD-friendly” language
is used in SBs (i.e., it would be easier to adopt the
SB language into the FAA AD).
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Federal AviationAdministration
ADF SBs, cont.
• (Goals, cont.)
– Referencing (relying on) the SB as the primary
source of information for compliance times and
actions in an AD in lieu of interpreting and re-keying
the SB information.
– Minimizing differences between SBs and ADs.
– Changing policies and procedures to increase both
SB and AD usability.
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Federal AviationAdministration
Harmonizing FAA ADs
• In addition to ADF with other countries, we
collaborated with EASA, ANAC, and TCCA
on terminology used in transport ADs—for
example:
– Consistent and precise general terminology.
– AD applicability.
– Enforceable compliance times.
– Required actions.
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Federal AviationAdministration
Advisory Circular (AC) 20-176A
• Design Approval Holder Best Practices for
SBs related to ADs:
– Making SBs more user-friendly (e.g., differentiating
critical tasks)
– Allowing later-approved parts
– Promoting global AMOCs
– Avoiding overlapping and conflicting SBs
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/979DDD1479E1
EC6F86257CFC0052D4E9?OpenDocument
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Federal AviationAdministration
Examples of ADF Elements
• Give clear explanations of the precipitating
event, cause, unsafe condition, and end-
level effect on the airplane.
• Use common and consistent descriptions
and terminology throughout the SB.
• Use precise and enforceable compliance
terminology (e.g., definitive compliance
times, inclusion of grace periods).
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Federal AviationAdministration
Examples of ADF Elements, cont.
• Always provide corrective actions to
address conditions that are found (e.g., a fix
is given if cracking is found).
• Include reporting requirements only when
essential.
• Provide repetitive inspections when
appropriate (e.g., when the root cause is not
yet identified).
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Federal AviationAdministration
Benefits of ADF SBs
• For the airlines:
─ Customer-oriented effort that supports FAA AD
drafting.
─ Reduced paperwork and resources for airlines, i.e.,
no need to correlate between SB and AD if the AD
simply references SB for compliance = less time
preparing work cards.
─ Easier to determine compliance.
─ Less need for questions to authorities/
manufacturers.
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Federal AviationAdministration
Benefits of ADF SBs, cont.
• For the manufacturer and the FAA:
─ Improved SB usability through commonality and
consistency.
─ Decreased delay and rework to develop ADs.
─ Fewer questions among the manufacturer, authority,
and operators.
─ Fewer AMOC requests.
• FAA has received positive feedback from
operators.
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Federal AviationAdministration
AD Aviation Rulemaking
Committee (ARC)• Background:
– AD ARC was chartered in 2009 to evaluate and
address recommendations from two reviews
following a compliance issue with a particular AD
and a subsequent AD audit.
• One key objective of the AD ARC:
– Revise the way SBs are written to avoid mandating
actions that are not required to meet the safety
intent of the AD; done by separating critical from
non-critical tasks.
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Federal AviationAdministration
Questions?
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